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Readers' forum: Brick wall

02 April 2019
Issue: 4690 / Categories: Forum & Feedback
Reclaiming withholding tax on Swiss company dividends.

Dividends received by UK residents from Swiss companies are subject to 35% withholding tax. Under Article 10 of the 2009 UK/Swiss double tax agreement the Swiss Federal Tax Administration (SFTA) cannot impose a tax charge greater than 15% of the gross dividend if the beneficial owner is UK resident.

It is therefore left to the investor or his agent to reclaim the remaining 20% withholding tax from the SFTA using the prescribed claim form 86.

I have prepared such claims for three clients had them stamped by HMRC and submitted them together with supporting vouchers to the Swiss Federal Tax Administration Eigerstrasse 65 CH-3003 Berne Switzerland but despite several reminders I have not had any form of response to claims submitted more than 
14 months ago.

I understand from articles published on the internet that there has been a long running dispute over...

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